Limitation for sales tax assessment cannot be cured by an extension granted after the statutory period expires.

An assessment framed after the limitation period prescribed by section 11(5) of the Punjab General Sales Tax Act, 1948 could not be sustained where the purported extension under section 11(10) was granted only after expiry of the statutory period. The Tribunal's view that such a late extension could not revive a time-barred assessment was held consistent with the High Court's earlier ruling on the same legal position. No substantial question of law arose, and the challenge to the Tribunal's order failed. The legal effect is that a belated assessment remains barred by limitation when the extension is made after the limitation period has already run out.

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Issues: Whether the assessment for the relevant year was barred by limitation under section 11 of the Punjab General Sales Tax Act, 1948 and whether the extension of time granted after expiry of the prescribed period could sustain the assessment.

Analysis: The assessment had to be framed within the period prescribed by section 11(5) of the Punjab General Sales Tax Act, 1948. The extension order under section 11(10) was made after the statutory period had already expired, and the Tribunal had already held that such extension could not validate the belated assessment. The High Court found that the Tribunal's view was consistent with its earlier decision on the same legal position, and therefore no substantial question of law arose.

Conclusion: The assessment was rightly held to be time-barred and the challenge to the Tribunal's order failed.

Final Conclusion: The legal effect of the decision is that a belated assessment made beyond the prescribed limitation could not be sustained when the purported extension was granted after expiry of the statutory period.

Ratio Decidendi: Where the statute prescribes a limitation period for assessment, an extension granted after expiry of that period cannot validate an assessment already barred by limitation.

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